If an organization described in section
501(c) or (d) is exempt from taxation under section
501(a) for any taxable year or a political organization is exempt from taxation under section
527 for any taxable year, the application filed by the organization with respect to which the Secretary made his determination that such organization was entitled to exemption under section
501(a) or notice of status filed by the organization under section
527(i), together with any papers submitted in support of such application or notice, and any letter or other document issued by the Internal Revenue Service with respect to such application or notice shall be open to public inspection at the national office of the Internal Revenue Service. In the case of any application or notice filed after the date of the enactment of this subparagraph, a copy of such application or notice and such letter or document shall be open to public inspection at the appropriate field office of the Internal Revenue Service (determined under regulations prescribed by the Secretary). Any inspection under this subparagraph may be made at such times, and in such manner, as the Secretary shall by regulations prescribe. After the application of any organization for exemption from taxation under section
501(a) has been opened to public inspection under this subparagraph, the Secretary shall, on the request of any person with respect to such organization, furnish a statement indicating the subsection and paragraph of section
501 which it has been determined describes such organization.

(B) Pension, etc., plans

The following shall be open to public inspection at such times and in such places as the Secretary may prescribe:

(i)any application filed with respect to the qualification of a pension, profit-sharing, or stock bonus plan under section
401(a) or
403(a), an individual retirement account described in section
408(a), or an individual retirement annuity described in section
408(b),

(ii)any application filed with respect to the exemption from tax under section 501(a) of an organization forming part of a plan or account referred to in clause (i),

(iii)any papers submitted in support of an application referred to in clause (i) or (ii), and

(iv)any letter or other document issued by the Internal Revenue Service and dealing with the qualification referred to in clause (i) or the exemption from tax referred to in clause (ii).

Except in the case of a plan participant, this subparagraph shall not apply to any plan referred to in clause (i) having not more than 25 participants.

(C) Certain names and compensation not to be opened to public inspection

In the case of any application, document, or other papers, referred to in subparagraph (B), information from which the compensation (including deferred compensation) of any individual may be ascertained shall not be open to public inspection under subparagraph (B).

(D) Withholding of certain other information

Upon request of the organization submitting any supporting papers described in subparagraph (A) or (B), the Secretary shall withhold from public inspection any information contained therein which he determines relates to any trade secret, patent, process, style of work, or apparatus, of the organization, if he determines that public disclosure of such information would adversely affect the organization. The Secretary shall withhold from public inspection any information contained in supporting papers described in subparagraph (A) or (B) the public disclosure of which he determines would adversely affect the national defense.

(A)the application for exemption of any organization described in section
501(c) or (d) which is exempt from taxation under section
501(a) for any taxable year or notice of status of any political organization which is exempt from taxation under section
527 for any taxable year, and any application referred to in subparagraph (B) of subsection (a)(1) of this section, and

(B)any other papers which are in the possession of the Secretary and which relate to such application,

as if such papers constituted returns.

(3) Information available on Internet and in person

(A) In general

The Secretary shall make publicly available, on the Internet and at the offices of the Internal Revenue Service—

(i)a list of all political organizations which file a notice with the Secretary under section
527(i), and

The Secretary shall make available the information required under subparagraph (A) not later than 5 business days after the Secretary receives a notice from a political organization under section
527(i).

(b) Inspection of annual returns

The information required to be furnished by sections
6033,
6034, and
6058, together with the names and addresses of such organizations and trusts, shall be made available to the public at such times and in such places as the Secretary may prescribe. Nothing in this subsection shall authorize the Secretary to disclose the name or address of any contributor to any organization or trust (other than a private foundation, as defined in section
509(a) or a political organization exempt from taxation under section
527) which is required to furnish such information. In the case of an organization described in section
501(d), this subsection shall not apply to copies referred to in section
6031(b) with respect to such organization. In the case of a trust which is required to file a return under section
6034(a), this subsection shall not apply to information regarding beneficiaries which are not organizations described in section
170(c). Any annual return which is filed under section
6011 by an organization described in section
501(c)(3) and which relates to any tax imposed by section
511 (relating to imposition of tax on unrelated business income of charitable, etc., organizations) shall be treated for purposes of this subsection in the same manner as if furnished under section
6033.

(c) Publication to State officials

(1) General rule for charitable organizations

In case of any organization which is described in section
501(c)(3) and exempt from taxation under section
501(a), or has applied under section
508(a) for recognition as an organization described in section
501(c)(3), the Secretary at such times and in such manner as he may by regulations prescribe shall—

(A)notify the appropriate State officer of a refusal to recognize such organization as an organization described in section 501(c)(3), or of the operation of such organization in a manner which does not meet, or no longer meets, the requirements of its exemption,

(B)notify the appropriate State officer of the mailing of a notice of deficiency of tax imposed under section
507 or chapter 41section
507 or chapter 41 or 42, and

(C)at the request of such appropriate State officer, make available for inspection and copying such returns, filed statements, records, reports, and other information, relating to a determination under subparagraph (A) or (B) as are relevant to any determination under State law.

In the case of an organization to which paragraph (1) applies, the Secretary may disclose to the appropriate State officer—

(i)a notice of proposed refusal to recognize such organization as an organization described in section
501(c)(3) or a notice of proposed revocation of such organization’s recognition as an organization exempt from taxation,

(ii)the issuance of a letter of proposed deficiency of tax imposed under section
507 or chapter 41section
507 or chapter 41 or 42, and

(iii)the names, addresses, and taxpayer identification numbers of organizations which have applied for recognition as organizations described in section
501(c)(3).

(B) Additional disclosures

Returns and return information of organizations with respect to which information is disclosed under subparagraph (A) may be made available for inspection by or disclosed to an appropriate State officer.

(C) Procedures for disclosure

Information may be inspected or disclosed under subparagraph (A) or (B) only—

(i)upon written request by an appropriate State officer, and

(ii)for the purpose of, and only to the extent necessary in, the administration of State laws regulating such organizations.

Such information may only be inspected by or disclosed to a person other than the appropriate State officer if such person is an officer or employee of the State and is designated by the appropriate State officer to receive the returns or return information under this paragraph on behalf of the appropriate State officer.

(D) Disclosures other than by request

The Secretary may make available for inspection or disclose returns and return information of an organization to which paragraph (1) applies to an appropriate State officer of any State if the Secretary determines that such returns or return information may constitute evidence of noncompliance under the laws within the jurisdiction of the appropriate State officer.

(3) Disclosure with respect to certain other exempt organizations

Upon written request by an appropriate State officer, the Secretary may make available for inspection or disclosure returns and return information of any organization described in section
501(c) (other than organizations described in paragraph (1) or (3) thereof) for the purpose of, and only to the extent necessary in, the administration of State laws regulating the solicitation or administration of the charitable funds or charitable assets of such organizations. Such information may only be inspected by or disclosed to a person other than the appropriate State officer if such person is an officer or employee of the State and is designated by the appropriate State officer to receive the returns or return information under this paragraph on behalf of the appropriate State officer.

(4) Use in civil judicial and administrative proceedings

Returns and return information disclosed pursuant to this subsection may be disclosed in civil administrative and civil judicial proceedings pertaining to the enforcement of State laws regulating such organizations in a manner prescribed by the Secretary similar to that for tax administration proceedings under section
6103(h)(4).

(5) No disclosure if impairment

Returns and return information shall not be disclosed under this subsection, or in any proceeding described in paragraph (4), to the extent that the Secretary determines that such disclosure would seriously impair Federal tax administration.

(6) Definitions

For purposes of this subsection—

(A) Return and return information

The terms “return” and “return information” have the respective meanings given to such terms by section
6103(b).

(B) Appropriate State officer

The term “appropriate State officer” means—

(i)the State attorney general,

(ii)the State tax officer,

(iii)in the case of an organization to which paragraph (1) applies, any other State official charged with overseeing organizations of the type described in section
501(c)(3), and

(iv)in the case of an organization to which paragraph (3) applies, the head of an agency designated by the State attorney general as having primary responsibility for overseeing the solicitation of funds for charitable purposes.

(d) Public inspection of certain annual returns, reports, applications for exemption, and notices of status

(1) In general

In the case of an organization described in subsection (c) or (d) ofsection
501 and exempt from taxation under section
501(a) or an organization exempt from taxation under section
527(a)—

(A)a copy of—

(i)the annual return filed under section
6033 (relating to returns by exempt organizations) by such organization,

(ii)any annual return which is filed under section
6011 by an organization described in section
501(c)(3) and which relates to any tax imposed by section
511 (relating to imposition of tax on unrelated business income of charitable, etc., organizations),

(iii)if the organization filed an application for recognition of exemption under section
501 or notice of status under section
527(i), the exempt status application materials or any notice materials of such organization, and

(iv)the reports filed under section
527(j) (relating to required disclosure of expenditures and contributions) by such organization,

shall be made available by such organization for inspection during regular business hours by any individual at the principal office of such organization and, if such organization regularly maintains 1 or more regional or district offices having 3 or more employees, at each such regional or district office, and

(B)upon request of an individual made at such principal office or such a regional or district office, a copy of such annual return, reports, and exempt status application materials or such notice materials shall be provided to such individual without charge other than a reasonable fee for any reproduction and mailing costs.

The request described in subparagraph (B) must be made in person or in writing. If such request is made in person, such copy shall be provided immediately and, if made in writing, shall be provided within 30 days.

(2) 3-year limitation on inspection of returns

Paragraph (1) shall apply to an annual return filed under section
6011 or
6033 only during the 3-year period beginning on the last day prescribed for filing such return (determined with regard to any extension of time for filing).

(3) Exceptions from disclosure requirement

(A) Nondisclosure of contributors, etc.

In the case of an organization which is not a private foundation (within the meaning of section
509(a)) or a political organization exempt from taxation under section
527, paragraph (1) shall not require the disclosure of the name or address of any contributor to the organization. In the case of an organization described in section
501(d), paragraph (1) shall not require the disclosure of the copies referred to in section
6031(b) with respect to such organization.

(B) Nondisclosure of certain other information

Paragraph (1) shall not require the disclosure of any information if the Secretary withheld such information from public inspection under subsection (a)(1)(D).

(4) Limitation on providing copies

Paragraph (1)(B) shall not apply to any request if, in accordance with regulations promulgated by the Secretary, the organization has made the requested documents widely available, or the Secretary determines, upon application by an organization, that such request is part of a harassment campaign and that compliance with such request is not in the public interest.

(5) Exempt status application materials

For purposes of paragraph (1), the term “exempt status application materials” means the application for recognition of exemption under section
501 and any papers submitted in support of such application and any letter or other document issued by the Internal Revenue Service with respect to such application.

The organizations referred to in paragraphs (1) and (2) of section
6033(d) shall comply with the requirements of this subsection relating to annual returns filed under section
6033 in the same manner as the organizations referred to in paragraph (1).

(6) 1 Notice materials

For purposes of paragraph (1), the term “notice materials” means the notice of status filed under section
527(i) and any papers submitted in support of such notice and any letter or other document issued by the Internal Revenue Service with respect to such notice.

(6) 1 Disclosure of reports by Internal Revenue Service

Any report filed by an organization under section
527(j) (relating to required disclosure of expenditures and contributions) shall be made available to the public at such times and in such places as the Secretary may prescribe.

The date of enactment of this subparagraph, referred to in subsec. (a)(1)(A), is Sept. 2, 1958.

Codification

Sections 1201(b)(3), 1224(a), (b)(4), and 1225(a) ofPub. L. 109–280, which directed the amendment of section
6104 without specifying the act to be amended, were executed to this section, which is section 6104 of the Internal Revenue Code of 1986, to reflect the probable intent of Congress. See 2006 Amendment notes below.

Subsec. (d)(1)(A)(ii). Pub. L. 110–172, § 3(g)(2), amended text generally. Prior to amendment, text read as follows: “any annual return filed under section
6011 which relates to any tax imposed by section
511 (relating to imposition of tax on unrelated business income of charitable, etc., organizations) by such organization, but only if such organization is described in section
501(c)(3),”.

2006—Subsec. (b). Pub. L. 109–280, § 1201(b)(3), inserted at end “In the case of a trust which is required to file a return under section
6034(a), this subsection shall not apply to information regarding beneficiaries which are not organizations described in section
170(c).” See Codification note above.

Subsec. (c)(2) to (6). Pub. L. 109–280, § 1224(a), added pars. (2) to (6) and struck out heading and text of former par. (2). Text read as follows: “For purposes of this subsection, the term ‘appropriate State officer’ means the State attorney general, State tax officer, or any State official charged with overseeing organizations of the type described in section
501(c)(3).” See Codification note above.

Subsec. (a)(1)(A). Pub. L. 106–230, § 1(b)(1)(A), in heading, inserted “or 527” after “section
501”, in first sentence, inserted “or a political organization is exempt from taxation under section
527 for any taxable year” after “taxable year” and “or notice of status filed by the organization under section
527(i)” before “, together”, in second sentence, inserted “or notice” after “any application”, in last sentence, inserted “for exemption from taxation under section
501(a)” after “any organization”, and inserted “or notice” after “such application”, wherever appearing.

Subsec. (a)(2)(A). Pub. L. 106–230, § 1(b)(3), inserted “or notice of status of any political organization which is exempt from taxation under section
527 for any taxable year” after “taxable year”.

1998—Subsec. (b). Pub. L. 105–206, § 6019(a), inserted at end “In the case of an organization described in section
501(d), this subsection shall not apply to copies referred to in section
6031(b) with respect to such organization.”

Subsec. (d). Pub. L. 105–277added subsec. (d) and struck out heading and text of former subsec. (d). Text read as follows: “The annual return required to be filed under section
6033 (relating to returns by exempt organizations) by any organization which is a private foundation within the meaning of section
509(a) shall be made available by the foundation managers for inspection at the principal office of the foundation during regular business hours by any citizen on request made within 180 days after the date of the publication of notice of its availability. Such notice shall be published, not later than the day prescribed for filing such annual return (determined with regard to any extension of time for filing), in a newspaper having general circulation in the county in which the principal office of the private foundation is located. The notice shall state that the annual return of the private foundation is available at its principal office for inspection during regular business hours by any citizen who requests it within 180 days after the date of such publication, and shall state the address and the telephone number of the private foundation’s principal office and the name of its principal manager.”

Subsec. (e). Pub. L. 105–277struck out subsec. (e), which consisted of pars. (1) to (3) relating to public inspection of certain annual returns and applications for exemption with a limitation of applicability of certain provisions.

Subsec. (e)(1)(C). Pub. L. 105–206, § 6019(b), inserted at end “In the case of an organization described in section
501(d), subparagraph (A) shall not require the disclosure of the copies referred to in section
6031(b) with respect to such organization.”

1996—Subsec. (e)(1)(A). Pub. L. 104–168, § 1313(a)(1), amended subpar. (A) generally. Prior to amendment, subpar. (A) read as follows: “During the 3-year period beginning on the filing date, a copy of the annual return filed under section
6033 (relating to returns by exempt organizations) by any organization to which this paragraph applies shall be made available by such organization for inspection during regular business hours by any individual at the principal office of the organization and, if such organization regularly maintains 1 or more regional or district offices having 3 or more employees, at each such regional or district office.”

Subsec. (e)(2)(A). Pub. L. 104–168, § 1313(a)(2), inserted before the period at end “(and, upon request of an individual made at such principal office or such a regional or district office, a copy of the material requested to be available for inspection under this subparagraph shall be provided (in accordance with the last sentence of paragraph (1)(A)) to such individual without charge other than reasonable fee for any reproduction and mailing costs)”.

Subsec. (d). Pub. L. 98–369, § 306(b), substituted “shall state the address and the telephone number of the private foundation’s principal office” for “shall state the address of the private foundation’s principal office”.

Subsec. (d). Pub. L. 96–603, § 1(b), substituted in heading “annual returns” for “annual reports” and in text “section
6033 (relating to returns by exempt organizations) by any organization which is a private foundation within the meaning of section
509(a)” for “section
6056 (relating to annual reports by private foundations)” and “annual return” for “annual report” wherever appearing.

Subsec. (b). Pub. L. 95–488, § 1(d)(2), struck out provisions exempting from applicability of this subsec. the information required by a trust described in section
501(c)(21).

Pub. L. 95–227, § 4(e)(2), inserted provisions exempting from applicability of this subsec. the information required by a trust described in section
501(c)(21).

1976—Subsec. (a). Pub. L. 94–455, §§ 1201(d)(1),
1906(b)(13)(A), struck out in pars. (1)(A), (B), (D), and (2) “or his delegate” after “Secretary” wherever appearing and inserted in par. (1)(A) “and any letter or other document issued by the Internal Revenue Service with respect to such application” after “in support of such application,” and “any such letter or document” after “a copy of such application”.

1974—Subsec. (a)(1). Pub. L. 93–406, § 1022(g)(1), substituted “Organizations described in section
501” for “In general” in heading for subpar. (A), added subpars. (B) and (C), redesignated existing subpar. (B) as (D), and in subpar. (D) as so redesignated substituted “Withholding of certain other information” for “Withholding of certain information” in heading and “subparagraph (A) or (B)” for “subparagraph (A)” in text.

Subsec. (b). Pub. L. 93–406, § 1022(g)(3), which purported to amend subsec. (b) by substituting “6956, and 6058” for “and 6056” was executed by substituting “6056, and 6058” for “and 6056” as the probable intent of Congress. See 1980 Amendment note above.

1969—Subsec. (b). Pub. L. 91–172, § 101(e)(1), (j)(36), inserted provision prohibiting disclosure by the Secretary or his delegate of the name or address of any contributor to any organization or trust other than a private foundation and inserted reference to section
6056.

Amendment by Pub. L. 110–172effective as if included in the provisions of the Pension Protection Act of 2006, Pub. L. 109–280, to which such amendment relates, see section 3(j) ofPub. L. 110–172, set out as a note under section
170 of this title.

Effective Date of 2006 Amendment

Amendment by section 1201(b)(3) ofPub. L. 109–280applicable to returns for taxable years beginning after Dec. 31, 2006, see section 1201(c)(2) ofPub. L. 109–280, set out as a note under section
6034 of this title.

Amendment by section 1224(a), (b)(4) ofPub. L. 109–280effective Aug. 17, 2006, but not applicable to requests made before such date, see section 1224(c) ofPub. L. 109–280, set out as a note under section
6103 of this title.

Pub. L. 109–280, title XII, § 1225(b),Aug. 17, 2006, 120 Stat. 1094, provided that: “The amendments made by this section [amending this section] shall apply to returns filed after the date of the enactment of this Act [Aug. 17, 2006].”

Pub. L. 106–554, § 1(a)(7) [title III, § 312(c)], Dec. 21, 2000, 114 Stat. 2763, 2763A–640, provided that: “The amendments made by this section [amending this section and provisions set out as a note under section
1 of this title] shall take effect as if included in the provisions of the Tax and Trade Relief Extension Act of 1998 [Pub. L. 105–277, div. J], to which they relate.”

Amendment by section 1(b) ofPub. L. 106–230effective July 1, 2000, except that amendment by section 1(b)(2) ofPub. L. 106–230effective 45 days after July 1, 2000, see section 1(d) ofPub. L. 106–230, set out as a note under section
527 of this title.

Amendment by section 3(b) ofPub. L. 106–230applicable to returns for taxable years beginning after June 30, 2000, see section 3(d) ofPub. L. 106–230, set out as a note under section
6012 of this title.

“(A) In general.—Except as provided in subparagraph (B), the amendments made by this subsection [amending this section and sections
6033,
6652,
6685, and
7207 of this title] shall apply to requests made after the later of December 31, 1998, or the 60th day after the Secretary of the Treasury first issues the regulations referred to in section 6104(d)(4) of the Internal Revenue Code of 1986, as amended by this section.

“(B) Publication of annual returns.—Section 6104(d) of such Code, as in effect before the amendments made by this subsection, shall not apply to any return the due date for which is after the date such amendments take effect under subparagraph (A).”

Effective Date of 1996 Amendment

Pub. L. 104–168, title XIII, § 1313(c),July 30, 1996, 110 Stat. 1480, provided that: “The amendments made by this section [amending this section and section
6685 of this title] shall apply to requests made on or after the 60th day after the Secretary of the Treasury first issues the regulations referred to section 6104(e)(3) of the Internal Revenue Code of 1986 (as added by subsection (a)(3)).”

Amendment by Pub. L. 95–488effective with respect to taxable years beginning after Dec. 31, 1977, and nothing in amendment by Pub. L. 95–488construed to permit disclosure of confidential business information of contributors to any trust described in section
501(c)(21), see section 1(e) ofPub. L. 95–488, set out as a note under section
192 of this title.

Amendment by Pub. L. 95–227applicable with respect to contributions, acts, and expenditures made after Dec. 31, 1977, in and for taxable years beginning after such date, see section 4(f) ofPub. L. 95–227, set out as an Effective Date note under section
192 of this title.

Effective Date of 1976 Amendment

Pub. L. 94–455, title XII, § 1201(d)(2),Oct. 4, 1976, 90 Stat. 1667, provided that: “The amendments made by this subsection [amending this section] apply to any letter or other document issued with respect to applications filed after October 31, 1976.”

Amendment by section 1307(d)(2)(B) ofPub. L. 94–455applicable on and after Oct. 4, 1976, see section 1307(e)(6) ofPub. L. 94–455, set out as a note under section
6001 of this title.

Pub. L. 85–866, title I, § 75(c),Sept. 2, 1958, 72 Stat. 1661, provided that: “The amendments made by subsection (a) [amending this section] shall take effect on the 60th day after the day on which this Act is enacted [Sept. 2, 1958]. The amendments made by subsection (b) [amending section
6033 of this title] shall apply to taxable years ending on or after December 31, 1958.”

Effect of Amendments on Existing Disclosures

Pub. L. 107–276, § 7,Nov. 2, 2002, 116 Stat. 1935, provided that: “Notices, reports, or returns that were required to be filed with the Secretary of the Treasury before the date of the enactment of the amendments made by this Act [Nov. 2, 2002] and that were disclosed by the Secretary of the Treasury consistent with the law in effect at the time of disclosure shall remain subject on and after such date to the disclosure provisions of section 6104 of the Internal Revenue Code of 1986.”

Written determinations for this section

These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.

Note that the IRS often titles documents in a very plain-vanilla, duplicative way. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. That is unlikely to be the case.

Release dates appear exactly as we get them from the IRS. Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion.